RMD for Spousal Beneficiary

Husband and wife are 50/50 owners of Company A that sponsors the Company A 401(k) Plan.  Husband dies in December 2019 at the age of 70.5.  Wife is age 58 and is sole beneficiary.  The required beginning date would have been April 1, 2020 but the 2019 RMD was not taken when CARES was enacted so no 2019 RMD has been distributed.

Wife wants to rollover Husband's 401(k) account balance into her 401(k) account.  Can she do this and avoid RMD's until she reaches age 72?  I don't see why not but the RMD rules with a deceased participant always trip me up.

Catch22PGM, I think that's right. Under 402(c), the surviving spouse can roll over anything that is an eligible rollover distribution (ERD). Of course, under 402(c)(4)(B), the RMDs that would otherwise have been required for 2019 would not be part of the ERD, but CARES Act 2203(a)(I)(ii) says the 2019 amount that would have had to be distributed in 2020 does not exist (legally) as an RMD.